12-01-2025 JDA Work Session Packet

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Joint Development Authority TCAAP Redevelopment Project larger than necessary for current system needs, as it formerly housed some Army equipment that was removed after this portion of the site was decommissioned. Access to the facility will be maintained to ensure Army and its contractors can continue to maintain the facility and fulfill their remedial obligations. Public Health & Safety: There have also been questions raised about the public health implications of the TGRS existing within a community. The TGRS emits low levels of volatile organic compounds (VOCs) into the air as the contaminants are removed from the groundwater, via the air stripping towers at Building 116. This approved remedial approach was known when the Army sold the site to the County, and all parties, including regulators, understood that the site was intended for redevelopment, with the majority of the site planned for housing. To align with the intended uses governed by the TRC, the Army is obligated to ensure that air emissions levels are below the level of human risk, as established by the EPA and MPCA. Prior to the Army’s groundwater remediation system optimization, the Army had begun to explore alternative treatment methods to address potential air emissions concerns. However, air emissions modeling data from the Army in 2020 for the TGRS system showed that air emissions were below risk levels. Further, since the full implementation of the TGRS optimization work in 2023, levels of contamination in the water being treated in Building 116 have decreased by approximately 80%, leading to a decrease in air contaminant emissions from the air stripping process. EPA and MPCA regulators have informally indicated that, based on the current models and this optimization work, they are not concerned that current emissions would be a public health risk. However, the Army remains obligated to complete updated emissions modeling and real-time sampling, under regulatory supervision before any construction occurs at Rice Creek Commons. Regulators will review all data to ensure air quality does not pose adverse risks in the short term for construction workers or long term for future residents, employees, and visitors. Authority and Approvals In addition to the Army ownership of Building 116, a collection of documents governs all Army cleanup activities and any proposed changes to the TGRS. These documents include: • Federal Facilities Agreement (FFA, 1987): A legally binding, three-party agreement among the Army, EPA, and MPCA, implemented under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), or Superfund law. It establishes cleanup schedules, milestones, and penalties for noncompliance. • Record of Decision (ROD, 1997): The legal document defining the final cleanup plan, including the design and operation of the TGRS. • Environmental Covenant (EC): Recorded on the property to manage land use and ensure long- term awareness of ongoing remediation activities. • Amended & Restated Quitclaim Deed (Property Deed): Documented transfer of RCC property from the Army to Ramsey County. Obligations within the deed require the ongoing operation of